Transcript Heritage University Hazardous Waste Regulatory Review Course

Hazardous Waste
Regulatory Training
ACUITY BRANDS
ATLANTA, GA
Presented by:
HERITAGE GROUP SAFETY
RCRA
More than 40 million tons of hazardous
waste are generated each year.
Most comes from large manufacturers,
refineries, factories and producers.
Some comes from printers, laundries,
photo labs, gas stations and other small
facilities.
Managing Hazardous Waste
Treating, storing and getting rid of
hazardous waste means different things
to different people.



Owners of businesses-comply with
Federal law.
Government official-ensure no harm to
people or property.
Concerned citizen-want assurance that
everyone handling HW knows what to do.
EPA and RCRA
Resource Conservation Recovery Act was
established in 1976.
EPA has been developing specific
requirements for handling HW to protect
human health and the environment.
EPA gave us a Christmas tree!
OSHA, DOT and Coast Guard are also
involved.
What Was It Like Before
RCRA?
Rivers, lakes and streams polluted.
News stories everyday concerning
random dumping.
The Main Players
Generators-companies that produce
HW.
Transporters-move it from one place
to another.
Waste Managers-treat, store and
ultimately get rid of HW.
What Is Hazardous Waste?
Any solid, liquid or gas waste, which if not
properly discarded would cause harm to
human health or the environment.
Characteristics of HW:




Ignitable
Corrosive
Reactive
Toxic
Where does it come from?
EPA estimates that approximately 9095% of HW is generated by large
companies.
The other 5-10% is generated by small
companies-known as small quantity
generators or SQG’s.
Listed Wastes
Non-Specific Sources-”generics”- solvents,
electroplating rinses, waste-water treatment
sludges and other metal treating sludges.
Specific Sources-from specific industriespaint, lead, ink, petroleum, pesticides,etc.
Discarded commercial products-or not
used for their intended purpose.
GENERATOR REQUIREMENTS
Bear principle responsibility for their
waste and:






Determine hazardability.
Obtain EPA ID number.
Use HW Manifest.
Proper packaging.
Proper labeling.
Ensure proper disposal.
GENERATORS
Can treat and
dispose on their
site-96%.
Hire off-site
managers-4%.
Must ensure
companies have EPA
authorization-waste
managers and
transporter.
Use of the Uniform Manifest
EPA form 870-22 tracks the waste from
“Cradle to Grave”.
Passed from one person to the next in
the chain.
The Manifest Identifies:



Type and quantity of waste.
The transporter.
TSD where waste is being shipped.
MANIFEST, continued
Generator must sign
the manifest, ensure
packaging and
labeling meet DOT
requirements, obtain
transporters
signature and supply
at least six copies of
the manifest.
Generator Must be Notified
In 35 days or call to
find if where the
waste is.
In 45 days or call
the EPA.
Packaging and Labeling
HW must be properly packaged to ensure
there is no significant release to the
environment. Meet DOT requirements.
Containers must be properly labeled and
placarded to identify what is being
transported, where it came from and where it
is going, and provide special handling
instructions.
Storing Hazardous Waste
Generators of more
than 2200 lbs.. In
one month may
accumulate and
store any amount up
to 90 days.
Storage
requirements apply.
Storing, continued
Generators of 2202200 pounds may
store up to 2200
pounds on site for
180 days or 270
days if the waste is
being shipped more
than 270 miles.
TRANSPORTERS
Responsible for spills during transport.
Must ensure wastes do not spread from
the scene, notifying proper authorities
and arranging for clean-up.
Must have EPA ID number.
Comply with manifest requirements.
Deliver the waste.
Ensure proper documentation.
Managing Hazardous Wastes
TSD’s are responsible for treating,
storing and getting rid of the waste per
Federal requirements.
General requirements”




EPA ID number.
Waste Analysis (waste analysis plan).
Permit to construct or operate.
Emergency Planning (contingency plan)
TSD’s continued
Manifest and Record Keeping.
Closure requirements.
Storage and Disposal
Tanks-above or under ground.




Concrete, Steel or Plastic.
Designed so it will not overflow.
If waste is fed continuously-it must have
equipment to control flow and alarm for
overflow.
Inspected regularly.
Land Disposal
Surface Impoundments
Landfills
Waste Piles
Land Treatment Units
Injection Wells
Incineration
Burning hazardous waste at high
temperatures.
Must be designed, constructed and
maintained so that it can remove all
(99.99%) of the hazardous elements of
the waste it is burning.
Liability Coverage
TSD’s - $ 1-2 million
Landfills - $ 3-6 million
Transporters - $ 5-7 million
Basic Requirements of
Hazardous Waste Generators
Basic Determinations
Identify Wastestreams
Hazardous Waste Determination
Determination of Regulatory Categories
Container Management
Standards
Containers Must Be . . .
In Good Condition
Compatible With the Waste
Labeled or Marked Clearly With the Words
"Hazardous Waste"
Marked With the Accumulation Start Date
Container Management
Standards (cont’d)
Kept Closed
Managed to Avoid Damage and
Releases
Incompatible Wastes Are Not to Be
Placed in the Same Container.
Subpart CC Air Emissions Standards
May Apply.
Container Accumulation Area
Standards
Ignitable/reactive Wastes Must Be 50 Ft.
From the Property Line
"No Smoking" Signs Must Be Posted
Incompatible Wastes Are to Be Separated
or Protected From Each Other
Emergency Equipment Is to Be Available
Adequate Aisle Space (2½ Feet) Is to Be
Maintained
Container Accumulation Area
Standards (cont’d)
Inspect Container Accumulation Areas
Weekly
Inspect Emergency Equipment at Least
Monthly
Shipments Are to Be Made Every 90
Days for Large Quantity Generators
Shipments Are to Be Made Every 180
Days for Small Quantity Generators
Compliance Documentation
Contingency Plan
Personnel Training Program & Records
Inspections
Manifests and LDR Forms
Biennial Reports
Waste Analyses/Determinations
Waste Minimization Program
Lists of Hazardous Wastes
(40 CFR Part 261, Subpart
D)
F-list
K-list
P-list
U-list
“Hazardous Wastes from
Non-Specific Sources” (40
CFR 261.31)
“F-List”
Generic Industrial Process
Wastes
Spent Solvents (F001-F005) (Not
Commercial Products or Manufacturing
Process Wastes) - “Solvent Mixture
Rule”
Electroplating Wastes (F006, F007,
F008, F009)
Generic Industrial Process
Wastes (cont’d)
Metal Heat-Treating Wastes (F010,
F011, F012)
WWT Sludges from Chemical
Conversion Coating of Aluminum (F019)
Miscellaneous
“Hazardous Wastes from
Specific Sources” (40 CFR
261.32)
“K-List”
Process Wastes from Specified
Industries
Wood Preservation
Inorganic Pigments
Organic Chemicals
Inorganic Chemicals
Pesticides
Explosives
Process Wastes from Specified
Industries (cont’d)
Petroleum Refining
Iron & Steel
Primary Copper
Primary Lead
Primary Zinc
Primary Aluminum
Process Wastes from Specified
Industries (cont’d)
Ferroalloys
Secondary Lead
Veterinary Pharmaceuticals
Ink Formulation
Coking
Acute Hazardous (H)
Wastes
(40 CFR 261.33(e))
“P-List”
P-List Examples
Mostly Pesticides, Organic Chemicals,
Cyanides, and Certain Heavy Metal
Compounds
Listings Include Unrinsed
Containers/Liners and Spill Residues
Lower Small-Quantity Generator
Exclusion (1 Kilogram/100 Kilograms
Spill Residue)
Toxic (T) Wastes
(40 CFR 261.33(f))
“U-List”
U-List
Mostly Natural and Synthetic Organics
Listings Include Spill Residues
Note
Commercial chemical product listings do not apply
to spent materials or manufacturing process
wastes containing listed chemicals. Listings apply
to technical grade chemicals or formulations where
the listed chemical is the sole active ingredient.
The commercial chemical products listings apply if
and when such chemicals are spilled, discarded or
intended to be discarded. Listings should be
consulted prior to disposal of virgin chemical spill
residues, off-specification chemical products,
manufacturing chemical intermediates, obsolete
chemical inventory, excess or surplus inventory, or
expired chemical products.
Solid Waste/Hazardous
Waste Determinations
(40 CFR 261.3)
Waste Material
Is the Waste Excluded From Definition
of Solid Waste (40 CFR 261.4(a) or by
Reuse or Recycling)?
Solid Waste
Is the Waste Excluded from Definition
of Hazardous Waste (40 CFR 261.4(b))?
Hazardous Waste
Listed (40 CFR 261, Subpart D
Mixture of Solid Waste and Listed
Hazardous Waste (40 CFR
261.3(a)(2)(iv))
Solid Waste Derived from T, S, or D of
Listed Hazardous Waste (40 CFR
261.3(c)(2)(i))
Waste Exhibits any Characteristics of
Hazardous Waste (40 CFR 261, Subpart
C - either by testing or knowledge of
waste)
Characteristics of Hazardous
Waste
(40 CFR Part 261, Subpart C)
Ignitability (I) D001
(40 CFR 261.21)
Liquid, With Closed Cup Flashpoint
<140F
Nonliquid, Capable of Spontaneous and
Sustained Combustion and When
Ignited, Burns So Vigorously and
Persistently As to Create a Hazard
DOT Oxidizers and Ignitable
Compressed Gases
Corrosivity (C) D002
(40 CFR 261.22)
Aqueous, pH  2 or pH  12.5
Liquid, Corrodes SAE 1020 Steel > 1/4"
Per Year at 130F
Reactivity (R) D003
(40 CFR 261.23)
Unstable, Reacts Violently
Water-reactive or Forms Potentially
Explosive Mixtures With Water
Forms Toxic Gases, Vapors, or Fumes
Endangering Health When Mixed
With Water
Cyanide or Sulfide Containing Waste
Which Can Generate Toxic Gases at
pH Conditions Between 2 and 12.
Reactivity (R) D003
EPA Guidance:
Reactive Cyanide (SW846-9010):
250 mg HCN/kg Waste
Reactive Sulfide (SW846-9030):
500 mg H2S/kg Waste
NOTE: Guidance retracted in 4/21/98 Internal
memo, but not replaced with alternate test
or numeral standards.
Reactivity (R) D003
Capable of Detonation or Explosive
Reaction
DOT Explosive (Class 1)
Toxicity (E) D004-D043
(40 CFR 261.24)
Toxicity Characteristic Leaching
Procedure (TCLP) Extract of Waste
Analyzed for Specified Heavy Metals
and Toxic Organics. Zero Headspace
Extraction (ZHE) Required for Volatile
Organic Constituents.
Toxicity (E) D004-D043
TCLP Extraction Developed to Simulate
Effects of Waste Mismanagement Upon
the Groundwater in a Municipal Landfill
Co-disposal Scenario. Regulatory
Thresholds Are Derived by Multiplying
the Chronic Toxicity Level (Typically
MCLs) by the Dilution Attenuation
Factor (DAF). DAF Is Currently Set at
100.
When Does a Solid Waste
Become a Hazardous
Waste?
A Waste Becomes Hazardous
When . . .
When It First Meets the Listing
Description
For Mixtures, When Listed Hazardous
Waste is First Added to Solid Waste
(“Mixture Rule” - 40 CFR
261.3(a)(2)(iv))
When the Waste Exhibits Any of the
Characteristics of Hazardous Waste
Note: Point of Generation to be Used for
Regulatory Purposes
Residues from Treatment,
Storage, or Disposal of
Listed Hazardous Waste
Remain Hazardous Wastes
Unless Delisted
Sludges
Treatment Residues
Spill Residues
Ash
Air Emission Control Sludge/Dust
Leachate
(“Derived From” Rule - 40 CFR 261.3(c)(2))
When Does A Hazardous
Waste Cease To Be A
Hazardous Waste?
A Waste Ceases To Be Hazardous
When . . .
Listed Waste, Mixtures With or Derived
From Listed Waste - When It Has Been
Excluded (Delisted) Under 40 CFR
260.20 and 260.22 and Does Not
Exhibit Any of the Characteristics.
A Waste Ceases To Be Hazardous
When . . .
Characteristic Waste - When It No
Longer Exhibits Any of the
Characteristics and Meets LDR
Treatment Standards (UTS) at 40
CFR 268.48.
NOTE: Many UTS limits are Lower
Than Characteristic Concentrations.
Exceptions To The Mixture Rule
Specified Wastewater Mixtures
Mixtures of Solid Waste and Hazardous
Waste Listed Solely for a Characteristic
(I,C,R, or E), Where Resulting Mixture
No Longer Exhibits Any Characteristics
(F003).
Exceptions To The "Derived
From" Rule
Lime Stabilized Waste Pickle Liquor
Sludge That Is Not Characteristically
Hazardous
Residues From Burning Certain Exempt
Petroleum Refinery Fuels
Exceptions To The "Derived
From" Rule (cont’d)
Hazardous Debris Meeting Debris LDR
Treatment Standards Using Extraction
Or Destruction Technologies
Delisted Waste Materials
Use and Management of
Containers
(40 CFR 265, Subpart I)
Use and Management of
Containers
Condition of Containers
(40 CFR 265.171)
Containers Must be in Good Condition
Contents of Leaking Containers Must be
Transferred or Container Overpacked
Use and Management of
Containers (cont’d)
Compatibility of Waste with
Container
(40 CFR 265.172)
Use and Management of
Containers (cont’d)
Management of Containers
(40 CFR 265.173)


Containers Must be Closed During Storage
Containers Must be Handled so as to Avoid
Rupture or Leakage
Use and Management of
Containers (cont’d)
Inspections
(40 CFR 265.174)
At Least Weekly
Use and Management of
Containers (cont’d)
Special Requirements for
Ignitable or Reactive Wastes
(40 CFR 265.176)
Must be Located at Least 50
Feet from Property Line
Use and Management of
Containers (cont’d)
Special Requirements for Incompatible
Wastes (40 CFR 265.177)
Must Not be Placed in Same Container
Must be Separated, or Protected by
Dike, Berm, Wall or Other Devices
Use and Management of
Containers (cont’d)
Air Emission Standards
Manage All Hazardous Waste in
Containers in Accordance With Subpart
CC of 40 CFR 265
Regulatory Categories
Regulatory Categories (cont’d)
Solid Waste/Non-Hazardous Industrial
Waste Generator
Conditionally-Exempt Generator (CESQG
<100 Kg/Mo)
Regulatory Categories (cont’d)
Small Quantity Generator (SQG: 100 1000 Kg/Mo)
Generator Who Accumulates On-Site in
Containers or Tanks for Less Than 90
Days (Large Quantity Generator or
LQG)
Note: The First Four Categories are
Mutually Exclusive at Any One Point In
Time.
Regulatory Categories (cont’d)
Generator/Shipper (to Off-site TSD)
Generator Who Stores On-site Under
RCRA Permit or Interim Status
Generator Who Treats On-site By an
Exempted Method or In an Exempted
Manner
Used Oil Generators, Transporters,
Processors/re-refiners, Burners and
Marketers
Regulatory Categories (cont’d)
Owner/Operator of Underground
Petroleum Or Hazardous Substance
Storage Tank
Generator Who Treats/Disposes On-Site
Under RCRA Permit or Interim Status
Commercial TSD Facility
Standards For Generators
(40 CFR 262)
Standards For Generators
Determine if Any Solid Wastes
Generated are Hazardous Wastes.
(262.11)
Notify EPA & Obtain an EPA
Identification Number Prior to On-Site
T,S,D, or Off-Site Transportation.
(262.12)
Keep Records of Waste Analyses &
Determinations for 3 Years. (262.40)
Generators Who
Accumulate
Accumulation Time
(40 CFR 262.34)
Accumulate on-site for 90 days or less
provided:
Use of Containers (40 CFR 265-Subpart I and
Subparts AA, BB, and CC as Applicable)
Tank Systems (40 CFR 265-Subpart J, Except
265.197(c) and 265.200 and Subparts AA,
BB, and CC as Applicable)
On Drip Pads (40 CFR 265 Subpart W)
Containment Buildings (40 CFR 265 - Subpart
DD)
Accumulation Time
Accumulation Start Date Marking (90
Day Limit -30 Day Extension Possible)
- Satellite Accumulation (40 CFR
262.34(c))
(Excess Accumulation Date Starts 90
Day Period)
Hazardous Waste
Marking/Labeling
Accumulation Time
“Accumulating Generators” must also comply
with:




Preparedness and Prevention (40 CFR
265-Subpart C)
Contingency Plan and Emergency
Procedures (40 CFR 265-Subpart D)
Personnel Training (40 CFR 265.16)
Waste Analysis Plan (40 CFR 268.7(a)(5))
- When Treating in Tanks or Containers OnSite
to Meet LDR
Note
Satellite Accumulation Provisions at 40
CFR 262.34(c).
Small Quantity Generator Provisions at
40 CFR 262.34(d).
Satellite Accumulation Points
(40 CFR 262.34(c))
Areas “At or Near Any Point of
Generation Where Wastes Initially
Accumulate, Which Is Under the Control
of the Operator of the Process
Generating the Waste".
Satellite Accumulation Points Are Not
Subject to the 90-day Accumulation
Standards That Apply to Central
Accumulation/Storage Areas.
Satellite Requirements
Wastes Must Be Placed in Containers
That Are in Good Condition.
Wastes Must Be Compatible With the
Containers.
Containers Must Always Be Closed,
Unless Wastes Are Being Added or
Removed.
Satellite Requirements (cont’d)
Containers Must Be Marked With the
Words "Hazardous Waste" or Other
Words That Identify the Contents of the
Containers.
Accumulation Limit of 55 Gallons of HW
(1 Qt. Of Acutely HW) Per Satellite
Area.
Satellite Requirements (cont’d)
Containers Must Be Marked With the
Accumulation Start Date When "Excess
Accumulation" Begins (When the
Container Is Filled to Capacity).
Full Containers Must Be Moved to 90day Accumulation Area Within 3 Days
After Being Filled to Capacity.
Satellite Requirements (cont’d)
Authorized States Are Not Required to
Adopt the Satellite Accumulation Rules.
Some States Have Set Time Limitations
on the Satellite Accumulation Period
Preparedness and Prevention
(40 CFR Part 265, Subpart C)
Preparedness and Prevention
Maintain and Operate the Facility So As to
Minimize the Possibility of Fire, Explosion
or Unplanned Release (265.31)
Provision of Certain Required Equipment
(265.32) :




Internal Communications or alarm system
Telephone or two-way radio
Portable fire extinguishers, fire control
equipment, spill control and decontamination
equipment
Water at adequate volume and pressure
Preparedness and Prevention
Testing and Maintenance of Equipment (265.33)



Must be tested and maintained.
Must have employee access to emergency equipment
and alarm.
If only 1 person on site, must have immediate access
to alarm or communication.
Aisle Space Required to Allow Emergency
Response (265.35)
Preparedness and Prevention
Arrangements With Local Authorities Must
be Attempted, as Appropriate(265.37):




Police, Fire, and Emergency Response Teams
Agreements Designating Primary Fire and
Police Authorities
Agreements With State Emergency Response
Teams, Emergency Response Contractors, and
Equipment Suppliers
Local Hospitals
Contingency Plans
(40 CFR Part 265, Subpart D)
Contents of Contingency Plan
Describe Actions of Facility Personnel in
Response to HW Emergencies.
Describe Arrangements Made With
Local Authorities, Responders.
List of Emergency Coordinators,
Addresses, and Phone Numbers.
Emergency Equipment List & Location
Evacuation Plan, Signal, and Routes.
Contingency Plans
Copies to be maintained at the facility.
Submitted to local agencies, hospitals,
and responders.
Review and amend upon changes of
information or the plan fails in an
emergency.
Emergency Coordinator to be on-site or
available at all times.
Personnel Training
(40 CFR 265.16)
Personnel Training
HazWaste Handling Personnel to be
Trained
Training by Person Trained in HazWaste
Management Procedures to train
Personnel in HazWaste Management
Procedures Relevant to their Job
Descriptions.
Personnel Training
Training to Include Responding to
Emergencies, Procedures, Equipment,
Systems.






Inspecting & Repairing Emergency
Equipment
Automatic Waste Feed Cut-off Systems
Communications and Alarm Systems
Response to Fire or Explosions
Response to Groundwater Contamination
Shutdown of Operations
Personnel Training
Training to be completed within 6 month of
employment.
Personnel must participate in annual review
of the initial training required.
Documented Recordkeeping:




Job title for each position at facility.
Written job description for each position.
Description of type and amount of training
to be received by each person/position.
Record of training received and job
experience.
Records kept until close of facility or three
years after employment terminates.
Note
Compliance With RCRA HWM Training
Requirements Is Not Adequate Training
for OSHA Hazard Communication
Standard or DOT HM-126F Compliance,
and May Not Be Adequate for
Compliance With the OSHA Hazardous
Waste and Emergency Response
Operations Standard.
Requirements for 100-1000
Kg/Month Small Quantity
Generators (40 CFR 262.34(d))
Notify and Obtain U.S. EPA ID Number
Accumulate No More Than 6,000 Kg
On-Site for Up to 180 Days (270 Days If
TSD Over 200 Miles Away)
Mark Each Container With the Words
“Hazardous Waste” and Accumulation
Start Date
Requirements (cont’d)
Follow Container Storage or Tank
Accumulation Requirements
Preparedness and Prevention
Requirements
Emergency Planning and Notification of
Releases
Requirements (cont’d)
Utilize Planning and Notification of
Releases
Follow DOT Requirements Re:
Packaging, Labeling and Marking
Use Uniform Hazardous Waste Manifest

Limited Exception Reporting Requirements
if Return Copy Not Received Within 60
Days of Shipment
Standards for Generators
Mixing Prohibition
Rebuttable Presumption
Comply With SPCC and UST
Regulations, As Applicable
Store Only in Tanks, Containers, or
RCRA Permitted Units
Standards for Generators
(cont’d)
Containers/Tanks Must Be in Good
Condition, Not Leaking and
Marked/labeled "Used Oil"
Label/mark Fill Pipes to USTs
Respond to Releases
Use Transporters With EPA
Identification Numbers
Standards for Transporters
and Transfer Facilities
Notify and Obtain EPA Identification Number
Store Used Oil in Labeled Containers/Tanks
Within Secondary Containment With
Impervious Floor for Less Than 35 Days
Track Incoming and Outgoing Used Oil
Determine Total Halogen Content of Used
Oil for Rebuttable Presumption Purposes
Respond to Releases and Properly Manage
Residues
Standards for Processors
and Re-refiners
Notify and Obtain EPA Identification
Number
Determine Total Halogen Content of
Used Oil for Rebuttable Presumption
Purposes
Store/process in Containers/tanks That
Are Labeled and in Good Condition
Within Secondary Containment With an
Impervious Floor
Standards for Processors
and Re-refiners (cont’d)
Respond to Releases and Properly
Manage Residues
Preparedness and Prevention
Contingency Plan
Written Analysis Plan
Standards for Processors
and Re-refiners (cont’d)
Operating Record/Tracking Log
Biennial Report
Closure Requirements
Generator Requirements
Eight Elements for LDR
Compliance
Determine, at the Point of Generation,
All Applicable Codes, the Category
(WW or Non-WW), and the
Subcategory (If Any) for Each
Restricted Waste.
Determine Which Treatment
Standard(s) Apply to Each Restricted
Waste
Eight Elements for LDR
Compliance (cont’d)
Identify Underlying Hazardous
Constituents (Where Required).
Determine, Through Specified Analytical
Techniques or Knowledge of the Waste,
Whether the Treatment Standard Has
Been Achieved.
Comply With Storage Time Limitations.
Eight Elements for LDR
Compliance (cont’d)
Comply with prohibitions on evaporation
and dilution.
Prepare notifications and/or
certifications required for onsite or
offsite waste management.
Comply with recordkeeping
requirements to maintain all LDR
documentation.
EPA/DOT Regulatory
Requirements
Generators Shipping
Hazardous Wastes Off-Site
Select Appropriate Shipping Description
and Determine If RQ Is Being Shipped
in a Single Container
Perform LDR determinations
Comply With DOT Requirements for
Packaging, Labeling, and Marking
Generators Shipping
Hazardous Wastes Off-Site
Container Labeling/Marking



Apply DOT Label (49 CFR 172)
Apply DOT Marking – Proper shipping name, ID
number (49 CFR 172)
Apply EPA Haz Waste Label
(Yellow – “Hazardous Waste –
Federal Law Prohibits Improper
Disposal….. + Generator name
and Address, Manifest document
number)
Generators Shipping
Hazardous Wastes Off-Site
Verify That Transporter and Designated
TSD Facility Have Valid EPA
Identification Numbers and Relevant
Permits
Generators Shipping
Hazardous Wastes Off-Site
Prepare a Uniform Hazardous Waste
Manifest (EPA Form 8700-22), Utilizing
Appropriate Form per Acquisition
Hierarchy. (State location of TSDF)
Prepare the Appropriate Notice(s) for
Restricted Waste Shipments to
Treatment Facilities.
Prepare the Appropriate Certification(s)
for Restricted Waste Shipments to Land
Disposal Facilities.
Generators Shipping
Hazardous Wastes Off-Site
Offer the Transporter Appropriate
Placards.
Sign and Date Manifest, Certifying
Shipment Meets EPA and DOT Pretransportation Requirements. Signature
also Certifies that a Waste Minimization
Program is in Place, and that the
Method of T, S, or D Selected is
Environmentally Appropriate.
Generators Shipping
Hazardous Wastes Off-Site
Obtain Print Name and Signature of
Transporter and Date of Acceptance
Retain one copy of
the signed manifest
and give the
remaining copies
to the transporter
Generators Shipping Hazardous
Wastes Off-Site
Monitor the Manifest Tracking System –
contact TSD if not received in 35 days.
Submit Exception Reports, as
Appropriate if original not received from
TSD within 45 days.
Prepare and Submit Biennial Reports
Including a Description of Waste
Minimization Efforts and Achievements.
Recordkeeping
Requirements
Keep Copies of Manifests, Land Disposal
Restriction Notices/ Certifications,
Biennial Reports, Any Exception
Reports, and Waste
Analyses/Determinations.
3 Years (extended during course of
unresolved enforcement action).
State – Annual Manifest Report